ANALYSIS

Cutting edge analysis on tax issues.

Sarah Bond

Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields Bruckhaus Deringer) discuss whether the UK terms should be given the broader meaning of the OECD concepts in order to bring greater clarity and reduce the risk of double taxation.

Marvin Reynolds

Lyndon Firth

Marvin Reynolds and Lyndon Firth (BDO) provide a refresher guide on the tests for TOGCs for VAT purposes.

Chris Sanger

The new chancellor has reset expectations with an almost total reversal of his predecessor’s mini-Budget, writes Chris Sanger (EY).

Lexis®PSL Tax and Private Client provide a summary of the key tax announcements made in the chancellor’s emergency statement and subsequent speech delivered to the House of Commons, on 17 October 2022 which unravelled most of the measures announced in the Growth Plan (the ‘mini-Budget’) on 23 September 2022. With practitioner comment and an additional timeline of recent announcements.

Paul Farmer

Simon Whitehead

Paul Farmer and Simon Whitehead (Joseph Hage Aaronson) consider how fiscal state aid issues should be addressed where the national tax provisions creating the aid are not based on a simple exemption from a standard rate but arise from differential rate regimes and asymmetric taxes.

Andrew Rainford

The tribunals appear keen to adopt an approach which is based in commercial reality, writes Andrew Rainford (Red Dragon Tax).

Klara Kronbergs

Edward Reed

Edward Reed and Klara Kronbergs (Macfarlanes) provide a round-up of the latest developments.

Andrew Howard

Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.

Zoe Andrews

Mike Lane

The decisions in Burlington and Aozora GMAC are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Nick Lindsay

Dhruv Patel

Nick Lindsay and Dhruv Patel (Elemental CoSec) review the requirements of registration in advance of the 31 January deadline and highlight the issues that are proving challenging for the industry.

Go to page of 438